UAB “Baltijos kelionės” understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.go2baltics.lt (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.
01. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Cookie – means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
Cookie Law – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
02. Information About Us
Our Site is owned and operated by UAB “Baltijos kelionės”, a limited liability company registered in Lithuania under company number 304143963.
Registered address: Laisvės al. 89-1C, LT-44297 Kaunas.
Email address: email@example.com.
Data Protection Officer: Matas Lasauskas.
Email address: firstname.lastname@example.org.
Telephone number: +370 686 99432.
03. What Does This Policy Cover?
04. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
05. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:
- The right to access the personal data We hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 13 to find out more.
- The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose of any of your personal data that We hold. Please contact Us using the details in Part 13 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to Us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to Us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about Our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 13.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep Us informed as long as We have that data.
Further information about your rights can also be obtained from the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija).
If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns Ourselves, however, so please contact Us first, using the details in Part 13.
06. What Data Do You Collect and How?
Other data we collect and process, regarding employment, administration of complaints or communicating with you:
1. The processing of your personal data
The processing of personal data in the selection of job candidates and the administration of the database of candidates
If we have received your CV (curriculum vitae), recommendation letter and / or other documents or data regarding an advertisement for a job offering, published by our website or you have voluntarily submitted your CV to a recruiting agency your personal data will be processed for the purpose of the selection of staff.
Your personal data will be processed until the selection ends, i.e. when it will be decided to accept a particular candidate for a job, end their probationary period or when it will be decided to complete the selection without the hiring of any candidate.
This period should not exceed 4 months. After the selection, your personal data will be stored for 3 years, so that upon a vacancy, we can offer you a proposal, unless you oppose or object to such further data retention. If you do not agree with the storage of your data after the end of the selection period, please inform us on the Subject Access Request Form by email or in any other convenient way for you.
Your personal data will be processed on the basis of your consent to participate in the selection of employees, as well as on the basis for a legitimate interest and the exercise of rights or obligations provided in legal acts.
If you voluntarily submit your personal data to us so that we can keep it in the database of candidates and, contact you, if necessary, we would store your personal data for 3 years.
Please be advised that we may contact your previous employers and ask them for their opinion about your qualifications, professional skills and business characteristics. However, your existing employer will not be asked without your explicit prior consent.
2. Administrating of complaints, inquiries or feedback
If you submit a complaint request or feedback by email or in any other way to us, your voluntarily submitted personal data will be processed for the purpose of this complaint, request or feedback.
If your complaint relates to a potential dispute, possible damage, etc., your personal data may be stored for a maximum period of 10 years. If personal data will not relate to a possible dispute, it will be deleted in a shorter period of time.
The processing of your personal data will be based on the expression of your consent, however, in certain cases, the basis for further storage of the complaint may become a legal right.
3. Communication by e-mail
According to the Data Protection Legislation, personal data is considered to be the content of correspondence by e-mail, even if the correspondents are employees of a legal entity. In this context, the content of the communication, as well as the email addresses, are subject to mandatory rules for the processing of personal data in accordance with the Data Protection Legislation.
The basis for the processing of your personal data is the expression of your consent to agree to communicate via e-mail and provide certain data. In addition, the processing of personal data may also be based on performance of the contract and fulfillment of the statutory obligations.
Your email address, correspondence and other related personal data will be processed in accordance with the principle of proportionality. These details will firstly be visible to the person you are directly emailing. However, in some cases, your correspondence may also be read by other employees, for example, an investigation into internal administration, possible violation of legal acts or the violation of internal rules, etc.
4. Direct marketing
With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email or telephone or post with information, news, and offers on Our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish Us to explain how the new purpose is compatible with the original, please contact Us using the details in Part 13.
If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows Us to do so.
In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
07. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
The security of your personal data is essential to Us, and to protect your data, We take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the State Data Protection Inspectorate where We are legally required to do so;
08. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
- In order to fulfill your ordered services, we will only provide as much of your personal information to our partners, as it will be necessary for the particular service to be performed;
- We may provide your personal data to our partners who carry out certain work and provide services (intermediaries who manage data for the purpose of concluding and administering contracts with customers; IT companies that handle data to ensure the development, improvement and maintenance of information systems; to our clients, who provide security and other services, including law, finance, tax, business management, personnel administration and accounting services);
- Your personal data may be provided to the court, law enforcement agencies or state institutions to the extent that such provision is provided by legal requirements (e.g. bailiffs, court orders, etc.);
- Your personal data may be provided to other entities only with your individual consent, if you would grant such consent on a case-by-case basis.
If any of your personal data is shared with a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, We will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation, as explained above in Part 9.
In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
09. How Can I Access My Personal Data?
If you want to know what personal data We have about you, you can ask Us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 13. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell Us everything We need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.
We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request.
You will be kept fully informed of Our progress.
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.
It is recommended that you keep your internet browser and operating system up-to- date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
11. How Do I Contact You?
To contact Us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Matas Lasauskas):
Email address: email@example.com.
Telephone number: +370 686 99432.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.